BEFORE THE

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

 

 ) 

Application of ) 

 ) 

ALASKA AIRLINES, INC. ) Docket DOT-OST-2010-_______

 ) 

for an exemption pursuant to 49 U.S.C. 40109 ) 

(Sacramento-Guadalajara; San Jose-Guadalajara) ) 

 ) 

APPLICATION FOR EXEMPTION

Communications with respect to this document should be addressed to: 

Kyle Levine, Esq. Marshall S. Sinick, Esq. 

Associate General Counsel, Squire, Sanders & Dempsey L.L.P. 

 Commercial Law and Litigation 1201 Pennsylvania Avenue, N.W. 

Alaska Airlines, Inc. Washington, D.C. 20004 

19300 International Boulevard (202) 626-6651 

Seattle, Washington 98188 msinick@ssd.com

Megan Lawrence, Esq. Counsel to Alaska Airlines, Inc. 

Managing Director, Government Affairs 

 and Community Relations 

Alaska Airlines, Inc. 

19300 International Boulevard 

Seattle, Washington 98188 

DATED: September 17, 2010 
BEFORE THE

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

 

 ) 

Application of ) 

 ) 

ALASKA AIRLINES, INC. ) Docket DOT-OST-2010-_______

 ) 

for an exemption pursuant to 49 U.S.C. 40109 ) 

(Sacramento-Guadalajara; San Jose-Guadalajara) ) 

 ) 

APPLICATION FOR EXEMPTION

 Pursuant to 49 U.S.C. 40109, 14 C.F.R. 302 and the Economic and Procedural 

Regulations of the Department of Transportation (the “Department”), Alaska Airlines, Inc. 

(“Alaska”) hereby requests an exemption from 49 U.S.C. 41101 and, to the extent 

necessary, from the Department’s regulations to permit Alaska to engage in the scheduled 

year-round foreign air transportation of persons, property and mail between: 

 (i) Sacramento, California, and Guadalajara, Mexico; and 

 (ii) San Jose, California, and Guadalajara, Mexico. 

Alaska requests that this exemption be granted for at least a two-year period. Alaska intends 

to begin services on these routes on December 15, 2010, and requests prompt approval so 

that marketing and selling can begin without delay. 

 In further support of its exemption request, Alaska states as follows: 

 1. Alaska’s principal headquarters are located at 19300 International 

Boulevard, Seattle, Washington. Alaska is incorporated under the laws of the State of 
Application of Alaska Airlines, Inc. 

Docket DOT-OST-2010-____ 

September 17, 2010 

2

Alaska and is a wholly-owned subsidiary of Alaska Air Group, Inc. (“AAG”). AAG is 

incorporated under the laws of the State of Delaware. 

 2. Alaska is a citizen of the United States within the meaning of 49 U.S.C. 

40102(a)(15). The president and at least two-thirds of Alaska’s directors and other 

managing officers are U.S. citizens. Additionally, to Alaska’s knowledge, U.S. citizens 

hold at least seventy-five percent of Alaska’s voting stock. 

 3. Alaska has repeatedly been found fit, willing and able to provide interstate 

and foreign air transportation. The Department is requested to take official notice of 

Alaska’s continuing fitness. See, e.g., Order 00-5-31. 

 4. Alaska will operate year-round services in the Sacramento-Guadalajara 

and San Jose-Guadalajara markets beginning December 15, 2010. Initial plans call for 

the operation of four weekly San Jose-Guadalajara and three weekly SacramentoGuadalajara roundtrip flights utilizing B737-800 aircraft seating up to 160 passengers. 

Alaska’s proposed schedules are attached to this application as Exhibit A. 

 5. On December 12, 2005, the United States and Mexico signed an 

amendment to the Air Transport Agreement of August 15, 1960, broadening air transport 

services between the two countries and permitting designated U.S. carriers to operate 

from “a point or points in the United States to a point or points in Mexico.”1

 The routes 

covered by this application are clearly within the scope of the amendments to the Air 

Transport Agreement and Alaska believes sufficient designations are available for its 

proposed services. All public interest considerations are therefore satisfied. 

 

1

 Annex I(A)1(a) 
Application of Alaska Airlines, Inc. 

Docket DOT-OST-2010-____ 

September 17, 2010 

3

 6. Alaska submits that its application raises no environmental or energy 

issues. Alaska’s flights will be operated with aircraft that meet all applicable noise 

abatement requirements. Nor will approval of this application result in an increase in fuel 

consumption of ten million gallons or more.

WHEREFORE, Alaska Airlines, Inc. respectfully requests that the Department 

of Transportation grant Alaska exemption authority for two years to operate scheduled 

services in foreign air transportation as more fully described herein, or such other relief as 

the Department deems necessary and appropriate. 

 Respectfully submitted, 

 ____________________________ 

 Marshall S. Sinick, Esq. 

 Squire, Sanders & Dempsey L.L.P. 

 1201 Pennsylvania Avenue, NW 

 Washington, D.C. 20004 

 Phone: (202) 626-6651 

 Msinick@ssd.com

 

 Counsel to Alaska Airlines, Inc. 

DATED: September 17, 2010
Exhibit A 

Alaska Airlines, Inc.

Proposed Year-Round Schedules 

San Jose-Guadalajara

Route Dep Arr 

Aircraft 

Type Seats Days of Operation Effective Fuel (gals) 

SJC-GDL 2355 0555+1 737-800 160 

Monday, 

Wednesday, 

Friday, Sunday 12/15/2010 3,000 

GDL-SJC 0700 0850 737-800 160 

Monday, Tuesday, 

Thursday, Saturday 12/15/2010 3,000 

Sacramento-Guadalajara

Route Dep Arr 

Aircraft 

Type Seats Days of Operation Effective Fuel (gals) 

SMF-GDL 2355 0555+1 737-800 160 

Tuesday, 

Thursday, Saturday 12/15/2010 3,000 

GDL-SMF 0700 0850 737-800 160 

Wednesday, 

Friday, Sunday 12/15/2010 3,000 
CERTIFICATE OF SERVICE

I hereby certify that one copy of the foregoing Application for Exemption has this 

day been served on each of the following individuals via e-mail.

 ________________________ 

 Marshall S. Sinick, Esq. 

DATED: September 17, 2010 

hkamen@coair.com; dan.weiss@coair.com

sascha.vanderbellen@delta.com; sametta.c.barnett@delta.com; jeff.morgan@delta.com

jeffrey.manley@united.com

anbird@fedex.com

dvaughan@kelleydrye.com; dfisher@kelleydrye.com

efaberman@wrf.com

howard_kass@usairways.com; benjamin.slocum@usairways.com

dkirstein@yklaw.com

jhill@dowlohnes.com

mlbenge@zsrlaw.com

pmurphy@lopmurphy.com

carl.nelson@aa.com

brian.gillman@mesa-air.com

Linda.lundell@dot.gov

esta.rosenberg@dot.gov

brian.hedberg@dot.gov